ML11245A083

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License Renewal Environmental Review (Shpo File No. Er 2004-2024-091-B)
ML11245A083
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 09/16/2011
From: David Wrona
License Renewal Projects Branch 2
To: Mcculloch T
US Advisory Council On Historic Preservation
Regner L
Shared Package
ML11245A085 List:
References
ER 2004-2024-091-B
Download: ML11245A083 (31)


Text

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NUCLEAR REGULATORY COMMISSION

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Mr. Tom McCulloch Office of Federal Agency Programs Advisory Council on Historic Preservation Old Post Office Building 1100 Pennsylvania Avenue, NW Suite 803 Washington, DC 20004

SUBJECT:

LIMERICK GENERATING STATION LICENSE RENEWAL ENVIRONMENTAL REVIEW (SHPO FILE NO. ER 2004-2024-091-B)

Dear Mr. McCulloch:

The U.S. Nuclear Regulatory Commission (NRC or the staff) is conducting an environmental review of the effects of renewing the operating licenses for Limerick Generating Station, Units 1 and 2 (Limerick). Limerick is located in the Limerick Township of Montgomery County, Pennsylvania; approximately 35 miles upriver from Philadelphia and is operated by Exelon Generation Company, LLC (Exelon). The application for renewal was submitted by Exelon in a letter dated June 22, 2011, pursuant to Title 10 of the Code of Federal Regulations (10 CFR)

Part 54.

The NRC has established that, as part of the staff's review of any nuclear power plant license renewal action, a site-specific Supplemental Environmental Impact Statement (SEIS) to its "Generic Environmental Impact Statement for License Renewal of Nuclear Plants,"

NUREG-1437, will be prepared under the provisions of 10 CFR Part 51, the NRC's regulation that implements the National Environmental Policy Act of 1969 (NEPA). In accordance with 36 CFR 800.8(c), the NRC staff is using the process required by NEPA for the preparation of the SEIS to comply with the obligations required under Section 106 of the National Historic Preservation Act of 1966, as amended (NHPA), in lieu of the procedures set forth in 36 CFR 800.3 through 800.6. Accordingly, the NRC staff is identifying parties who may wish to consult with the staff on the proposed action and is inviting them to do so. Consultation will include partiCipation in the scoping process, identification of historic properties at the Limerick plant site, assessment of the effects of the proposed action on any historic properties identified, and development of alternatives and proposed measures that might avoid, minimize, or mitigate any adverse effects of the proposed action on historic properties. The SEIS will include analyses of potential impacts to historic properties that reflect consultation and will document the NRC staff's determination regarding potential impacts to historic properties as a result of license renewal.

Through this letter, the NRC is initiating consultation under Section 106 of the NHPA with the Pennsylvania State Historic Preservation Office (SHPO) and the Advisory Council on Historic Preservation, regarding the Limerick license renewal application. In the context of NHPA, the NRC staff has determined that the area of potential effects (APE) for a license renewal action is the area at the power plant site and its immediate environs that may be impacted by post-license renewal land-disturbing operations or projected refurbishment activities associated with the proposed action. The APE may extend beyond the immediate environs in those instances where post-license renewal land-disturbing operations or projected refurbishment

T. McCulloch -2 activities specifically related to license renewal may potentially have an effect on known or proposed historic sites. This determination is made irrespective of ownership or control of the lands of interest.

The applicant corresponded with the Pennsylvania SHPO by letter dated January 19,2011.

They replied by letter dated February 16, 2011, that there are historic resources eligible for the National Register of Historic Places located in the area, but that there will likely be no effect on the properties. The Pennsylvania SHPO has been asked to confirm this information with the NRC staff in order to avoid any duplication of effort. Please provide any other information you consider appropriate under the provisions of Section 106 of the NHPA. Both the January letter from Exelon and the February 2011 letter from the Pennsylvania SHPO are enclosed for your reference (Enclosures 1 and 2).

To complete consultation under 36 CFR SOO.S(c), the staff will forward the draft SEIS to consulting parties for review and comment, and will address the comments in the final SEIS.

Your office will receive a copy of the draft SEIS along with a request for comments after it is issued. This draft SEIS will include identification of historic properties, assessment of impacts, and our preliminary determination of their suitability for listing in the National Register of Historic Places. The anticipated publication date for the draft SEIS is August 2012.

The NRC plans to hold two public license renewal overview and environmental scoping meetings on September 22,2011. The first session will be held in the afternoon, and an identical session will be held later that evening. Both sessions will be held at the Sunnybrook Ballroom, 50 Sunnybrook Road, Pottstown, PA 19464. The afternoon session will be from 2:00 PM to 4:00 PM, and the evening session will be from 7:00 PM to 9:00 PM. In addition, the NRC plans to hold a one hour Open House prior to each meeting to answer public questions.

You and your staff are invited to attend the public meetings and Open Houses.

T. McCulloch -3 The Limerick license renewal application is available on the internet at http://www.nrc.gov/reactors/operating/licensing/renewal/applications/limerick.html.

If you have any questions or require additional information, please contact Ms. Lisa M. Regner, License Renewal Project Manager, by phone at 301-415-1906 or bye-mail at Lisa.Regner@nrc.gov.

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David J. Wrona, Chief Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosures:

As stated cc: Listserv

Michael P. GallagheT, PE Telephone 610,765,5958 Exelon Vice President www.exelcncorp,coJTI Nuclear License Renewa! Project, mkhaeip,gaiiagher@exeloncorp.com Exeion Nuclear 200 Exelon Way KSAi2*E Kennett Square. PA 19348 January 19, 2011 Ms. Jean Cutler Deputy State Historic Preservation Officer Pennsylvania Historical and Museum Commission Bureau for Historic Preservation Commonwealth Keystone Building, 2 nd floor 400 North Street Harrisburg, PA 17120-0093 Re: Renewal of Operating Licenses for Limerick Generating Station, Units 1 and 2 Request for Information on Historic and Archaeological Resources

Dear Ms. Cutler,

In mid-2011, Exelon Generation Company, LLC (Exelon Generation; a subsidiary of Exelon Corporation) plans to apply to the U.S. Nuclear Regulatory Commission (NRC) for renewal of the operating licenses for Limerick Generating Station, Units 1 and 2 (LGS). The existing license for Unit 1 will expire on October 26, 2024 and the existing license for Unit 2 will expire on June 22, 2029. The renewal term for each unit would be an additional twenty years beyond the existing license expiration date.

The NRC requires that license renewal applications include environmental reports assessing potential environmental impacts from license renewal activities. One such impact would be effects of license renewal activities on historic or archaeological resources (10 CFR 51.53).

Accordingly, we are contacting you to obtain input for use in ~ddressing these effects in the LGS license renewal environmental report. Later, NRC may also request an informal consultation with your office under Section 106 of the National Historic Preservation Act of 1966, as amended (16 USC 470), and Federal Advisory Council on Historic Preservation regulations (36 CFR 800).

Project Features LGS existing features that are relevant to the effects of license renewal on historic and archaeological resources include the following:

Ms. Jean Cutler January 19, 2011 Page 20f4

1. The LGS plant site, which hosts the two generating units, is located on Exelon Generation-owned properties that are mostly situated in Limerick Township, Montgomery County, but some of which are in the adjacent Lower Pottsgrove Township, Montgomery County and directly across the Schuylkill River in East Coventry Township, Chester County.
2. The LGS makeup water supply system, which conveys water from approved sources to LGS for use in its circulating water system, is composed of the following components:

o The Perkiomen Pumphouse, located in Graterford Township, Montgomery County, and an associated underground 7.6-mile long Perkiomen Pumphouse-to LGS pipeline; both are located along an easement held by Exelon Generation within an electrical transmission line right-of-way (ROW) controlled by PECO, a subsidiary of Exelon Corporation; o The Bradshaw Reservoir and Bradshaw Pumphouse, which are both situated in Plumstead Township, Bucks County, on Exelon Generation-owned properties totaling 42-acres; o The Bedminster Water Processing Facility, which is situated in Bedminster Township, Bucks County, on a 3-acre Exelon Generation-owned property; and o An underground water transmission main, which is routed within a natural gas pipeline ROW along an easement held by Exelon Generation that runs from the Bradshaw Pumphouse to the East Branch Perkiomen Creek by way of the Bedminster Facility.

The buried Perkiomen Pumphouse-to-LGS water pipeline and the underground water transmission main are located below ground within ROWs that exist for other purposes, and their operation requires no independent vegetation management or ground disturbing activities along these ROWs. Hence, these underground components of the makeup water supply system are assumed to have no effects on archaeological and historical resources.

3. The LGS transmission system is composed of the following components:

o Two electrical transmission lines constructed to connect the LGS main power transformers with two electrical substations (these components are located on the LGS plant site); and o Four 230-kiloVolt (kV) and one 500-kV electrical transmission lines, with associated structures and offsite electrical substations, constructed to connect the onsite electrical substations to the regional electricity grid.

All offsite substations and transmission lines are operated by PECO and are located in ROWs situated in Montgomery and Chester Counties either on PECO-owned properties or on properties for which PECO holds permits, grants, easements, or licenses. Onsite transmission lines traverse only land disturbed during initial plant construction.

Figures 1 through 9, showing the locations of the existing LGS project features, are provided in .

Ms. Jean Cutler January 19, 2011 Page 30f4 Activities During the License Renewal Terms LGS license renewal will involve no new construction, refurbishment, ground disturbing activities, changes to operations, or changes to existing land-use conditions. Operation and maintenance activities during the terms of the renewed LGS licenses are only expected to occur in previously disturbed areas or existing ROWs. Hence, no new adverse impacts to known or undocumented archaeological or historical resources are anticipated from license renewal.

Notwithstanding, to protect such resources that may be located in previously undeveloped areas on Exelon Generation-owned properties associated with LGS, Exelon Generation has developed a comprehensive Cultural Resources Management Plan ("CRMP"), which will be in place during the period of extended operation. In addition, Exelon Generation has obtained a Historic Architectural Assessment of extant structures contained within the Fricks Lock Historic District, located on Exelon Generation-owned property in East Coventry Township, Chester County. Discussions with township officials are in progress regarding future management of this historiC district.

Identification of Cultural Resources Using the Pennsylvania Cultural Resources Geographic Information System ("CRGIS") on-line database, historic properties and archaeological sites listed on and determined eligible for the National Register of HistoriC Places within a six-mile radius of the LGS plant site have been identified and are listed in the enclosed Attachment 1, Tables 1 through 3. Exelon Generation will provide this information to the NRC in the LGS license renewal environmental report.

Additionally, the NRC will be informed about cultural resources investigations that have been performed previously on land now occupied by the LGS plant site, the LGS makeup water supply system, and the LGS transmission system ROWs. Such investigations are described in the enclosed Attachment 2.

Because license renewal involves no new construction, refurbishment, ground disturbing activities, changes to operation, or changes to existing land use conditions, Exelon Generation does not expect LGS license renewal to adversely affect archeological or historic resources located near the LGS ptant site, makeup water supply system, or transmission system ROWs.

Nevertheless. we are requesting your help to identify issues we may have overlooked that need to be addressed in the LGS license renewal environmental report. We are also interested in learning of any information your staff believes could help expedite the NRC's review of the LGS license renewal application. Hence. in closing, we would appreciate receiving a response from you detailing such issues and information for the LGS plant site. makeup water supply system and transmission system. We would also welcome your confirmation of our conclusion that LGS license renewal would not adversely affect cultural resources.

Because we plan to incorporate a copy of your response, as well as this letter, into the LGS license renewal environmental report that will be submitted to the NRC as part of the LGS license renewal application. your response will be most helpful if we receive it by March 10, 2011.

Ms. Jean Cutler January 19, 2011 Page 4 of4 Please call Nancy Ranek (610-765-5369), our License Renewal Environmental Lead, if there are questions or you require additional information.

Sincerely, Michael P. Gallagher

Enclosures:

Attachment 1: Tables 1-3, Historic above-ground resources and archaeological sites within a 6-mile radius of Limerick Generating Station Attachment 2: Previous Cultural Resource Impact Investigations of LGS Features Attachment 3: Figures Depicting LGS Project Features (Figures 1 through 9)

Ms. Jean Cutler Attachment 1 January 19, 2011 Page 1 of?

Attachme nt 1 Historic above-ground resources and archaeological sites Within a 6-mile radius of Limerick Generating Station Table 1 Historic above-ground resources within a 6-mile radius of Limerick Generating Station that are listed in the National Register of Historic Places ............................................................................... 2 Table 2 Historic above-ground resources within a 6-mile Radius of Limerick Generating Station determined eligible for Listing in the National Register of Historic Places................................................................ 4 Table 3 Archaeological sites within a 6-mile Radius of Limerick Generating Station that have been determined eligible for Listing in the National Register of Historic Places . .................................................... 7

Attachment 1 January 19, 2011 Page 20f7 Table 1 Historic above-ground resources within a 6-mile radius of Limerick Generating Station that are listed in the National Register of Historic Places Site Name Location PHMC Key #

Fricks Locks Historic District Fricks Locks Road, End, 1/4 Mile East of 116261 Sanatoga Road, East Coventry Twp.,

Chester Co.

Hare's Hill Road Bridge East Pikeland Twp., Chester Co. 001553 Kimberton Historic District Hares Hill Road, Prizer Road, and 001562 (Boundary Increase) Kimberton Road, East Pikeland Twp.,

Chester Co.

Kimberton Village Historic District Intersection of Kimberton Road & Hares 104837 Hill Road, East Pikeland Twp., Chester Co.

Prizer's Mill Complex Mill Lane, East Pikeland Twp., Chester Co. 001580 Rapp's Covered Bridge Rapp's Dam Road, East Pikeland Twp., 000375 Chester Co.

Hall's Bridge East Vincent Twp., Chester Co. 001551 Kennedy Covered Bridge Seven Stars Road, East Vincent Twp., 050742 Chester Co.

Parker's Ford Old Schuylkill Road, East Vincent Twp., 079670 Chester Co.

  • River Bend Farm Sanatoga Road, East Vincent Twp . 050884 Chester Co. (Not in East Vincent Twp.)

Vincent Forge Mansion Cook's Glen Road, East Vincent Twp., 082618 Chester Co.

. Pottstown Landing Historic District Main Street, North Coventry Twp., Chester 104047 Co.

Coventryville Historic District Route 23, South Coventry, Warwick, and 001531 East Nantmeal Twps., Chester Co.

French Creek Farm Kimberton Road, West Vincent Twp., 095688 Chester Co.

Simon Meredith House Pughtown Road, South Coventry Twp., 050889 Chester Co.

Stephen Meredith House South Coventry Twp. 079484 Nathan Michener House Ridge Road, South Coventry Twp., 001574 Chester Co.

S.R. 7015 West Vincent Twp., Chester Co. 132272 William and Mordecai Evans 206 Main Street, Limerick Twp., .079687 House Montgomery Co.

Isaac Hunsberger House 545 West Ridge Pike, Limerick Twp., 087972 Montgomery Co.

Sanatoga Union Sunday School 2341 East High Street, Lower Pottsgrove 084422 Twp., MontgomeryCo.

Attachment 1 January 19, 2011 Page 3 of7 Site Name Location PHMC Key #

i Sunnybrook Park & Ballroom; 99 Sunnybrook Road, Lower Pottsgrove 140507 Sunnybrook Convention Center: Twp., Montgomery Co.

Colonial Restaurant; Sunnybrook Long Meadow Farm - Plank House New Hanover Twp., Montgomery Twp. 000561 and Barn High Street Historic District; Hill 631-1329 High Street, Pottstown Borough, 096230

! Historic District Montgomery Co.

Jefferson School Pottstown Borough, Montgomery Co. 118680 I John Potts House; Pottsgrove High Street, Pottstown Borough,  ! 000565 Mansion Montgomery Co.

Old Pottstown Historic District Manatawny Creek, Beech Street, Adams 064416 Street, Apple Street, and Hanover Street, Pottstown Borough, Montgomery Co.

Old Pottstown Historic District High & South Hanover Streets, Pottstown 077112 Boundary Increase Borough, Montgomery Co.

Pottstown Roller Mill Pottstown Borough, Montgomery Co. 000566 Reading Railroad: Station High Street, Pottstown Borough, 064347 (Pottstown) Montgomery Co.

William Grubb Mansion 1304 East High Street, Pottstown Borough, 096664 Montgomery Co.

Continental Stove Works; 1st Street, Royersford Borough, 082496 Buckwalter Stove Company Montgomery Co.

Augustus Lutheran Church Trappe Borough, Montgomery Co. 000789 (NHL)

Henry Melchior Muhlenberg house 201 West Main Street, Trappe Borough, 079790 Montgomery Co.

Henry Antes House Upper Frederick Twp., Montgomery Co. 000788 (NHL)

Bridge in Upper Frederick Twp.  ! L.R. 46007, Crossing Swamp Creek, I 000217 Upper Frederick Twp., Montgomery Co.

John Englehardt Homestead Keyser Road, 1 mile South of Obelisk, 000533 Upper Frederick Twp., Montgomery Co.

Sunrise Mill Neiffer Road, at Swamp Creek Road, 000575 Upper Frederick Twp., Montgomery Co.

Attachment 1 January 19. 2011 Page 4of7 Table 2 Historic above-ground resources within a 6-mile Radius of Limerick Generating Station determined eligible for Listing in the National Register of Historic Places.

Site Name Location PHMC Key #

John Mattis Farm 250 Kolb Road, East Coventry Twp. 121479 Chester Co.

Bridge S. R. 7015, East Coventry Twp., Chester 132046 Co.

Schuylkill Navigation Company East Coventry Twp., Chester Co. 140714 Canal Daniel H. Kulp House 131 Mack Road, East Coventry Twp., 141504 Chester Co.

Queen Anne House East Rapp's Dam Road, East Pikeland 022358 Twp., Chester Co.

Bernard Property Hares Hill Road, East Pikeland Twp., 105434 Chester Co.

Pennhurst State Hospital & Home East Vincent Twp., Chester Co.

  • 064464 Pennhurst State Hospital East Vincent Twp., Chester Co. 064464 Jonathon Rogers or Jacob Beaver West Seven Stars Road, East Vincent 079511 House Twp., Chester Co.

Egress Acres East Vincent Twp., Chester Co. 097182 William Yeager Farm Hoffecker Road, East Vincent Twp., 097300 I Chester Co.

Frank Titanic Property Bertolet School Road, East Vincent Twp., 097518 Chester Co.

  • Samuel Rosen Farm Ellis Wood Road, East Vincent Twp., 097621 Chester Co.

Camp Sankanac 66 Bertolet School Road, East Vincent 101617 Twp., Chester Co.

Bridge S.R. 7015 Crossing Pigeon Creek, East 132046 Coventry Twp., Chester Co.

S.R. 7015 East Vincent Twp., Chester Co. 132082 Isaac Schlichter House & Bam Stony Run Road, East Vincent Twp., 105032 Chester Co.

Parsonage, Falkner Swamp 117 Cross Road, New Hanover Twp., 079899 Reformed Church Montgomery Co.

Elliott Farm

  • North side of Fagleysville RoadNVagner 105340 Road, New Hanover Twp., Montgomery Co.  !

Ira Gruber Estate Schuylkill Road, North Coventry Twp., 022543 Chester Co. I

Attachment 1 January 19, 2011 Page 5 of7

Site Name Location PHMC Key #

Farmers Hall Church Street, North Coventry Twp., 079383 Chester Co.

Shaner's Bakery 482 Laurelwood Road, North Coventry 096338 Twp., Chester Co.

Walters Tract Subdivision 1338 West Schuylkill Road, North Coventry 105024 Twp., Chester Co.

S.R. 0724 Laurel Locks Farm, North Coventry Twp., 127053 Chester Co.

Kenilworth Historic District  ! Schuylkill Road, North Coventry Twp., 140712 Chester Co.

I Schuylkill Navigation Company North Coventry Twp., Chester Co. 140714

. Canal Spring City Historic District Spring City Borough, Chester Co.  ! 000042

! Textile Mill Spring City Borough, Chester Co. 105474 Gilbert Farm 1447 Grosser Road, Douglass Twp., 085684 Montgomery Twp.

Georg Michael Kuntz Homestead Limerick Twp., Montgomery Co. 079713 Williams Evans House 61 South Reed Road, Limerick Twp., 085618 Montgomery Co.

Hood Mansion Sanatoga Road, Limerick Twp., 096337 Montgomery Co.

Property A Limerick Twp., Montgomery Co. 097192

! Linfield Road House Linfield Road, Limerick Twp., Montgomery 097304 Co.

I Limerick Historic District Ridge Pike at U.S. 422, Limerick Twp., 097846 Montgomery Co.

Fruitville Road Stone Arch Bridge Fruitville Road, Limerick Twp., Montgomery 121481 Co.

(Not named in CRGIS record) 52 Keen Road, Limerick Twp., Montgomery 140444 Co.

Old Perkiomen Copper Mine Bounded Roughly by Swamp Creek, Mine 111282 Run, and Perkiomen Creek, Lower Frederick Twp., Montgomery Co.

Saylor Property 1559 North Pleasant View Road, Lower 121767 Pottsgrove Twp., Montgomery Co.

Jacobs Aircraft Engine Company 351-375 Armand Hammer Boulevard, 124550 Property Lower Pottsgrove Twp., Montgomery Co.

The Hill School High St. Pottstown Borough, Montgomery 050663 Co.

Henry Potts House 720 High Street, Pottstown Borough 086593 Montgomery Co.

Attachment 1 January 19, 2011 Page 6 of7

!

Site Name Location PHMC Key #

I Glasgow Village 1300 Glasgow Street, Pottstown Borough. 091053 Montgomery Co.

Charlotte Street Historic District 220-878 Charlotte Street, Pottstown 102254 Borough. Montgomery Co.

W.W. Rupert Elementary School Pottstown Borough, Montgomery Co. 115932 Pottstown Conservation District Pottstown Borough. Montgomery Co. 119061 Pottstown Industrial Historic District Queen Street. Moser Street. and 121485

. Susquehanna River. Pottstown Borough.

  • Montgomery Co.

S.R. 7046 Pottstown Borough. Montgomery Co. 136796 W.L Latshaw House (Meridan 134 North 4th Avenue. Royersford 085452 Youth Services) Borough. Montgomery Co.

Diamond Glass Co. 200-280 First Avenue, Royersford 141672 Borough, Montgomery Co.

Lamb Tavern 724 Main Street, Trappe Borough, 079653 Montgomery Co.

Dewees Tavern & Dwelling 301-307 Main Street, Trappe Borough, 079622 Montgomery Co.

Village of Trappe Historic District 151-724 Main Street, 18-24 East 3rd 106251 Avenue, 20-60 West 5th Avenue, 15-71 West 7th Avenue. Trappe Borough, Montgomery Co. I Senator Lewis Royer Farm 96 East 3rd Street, Trappe Borough, 106257

  • Montgomery Co.

Jan Neuss Log House Colonial Road, Upper Frederick Twp., 079781 Montgomery Co.

Bertolet's Mennonite Meeting Colonial Road, 1 mile West of Route 73, 096922 House Upper Frederick Twp., Montgomery Co.

(Not named in CRGIS record) 2nd Avenue, Upper Providence Twp., 000216 Montgomery Co.

Vanderslice/Custer Farm; Guy F. & 357 Greenwood Avenue, Upper 103213 Eleanor Wagner Providence Twp., Montgomery Co.

Hildebidle Property; Mourar 1637 Yeager Rd. Upper Providence Twp., 104182 *

! Property Montgomery Co.

S.R. 7046 Upper Providence Twp., Montgomery Co. 136891 Gudebrod Brothers Silk Company Old Reading Pike, West Pottsgrove Twp., 091862 Montgomery Co.

Attachment 1 January 19, 2011 Page 7 of 7 Table 3 Archaeological sites within a 6-mile Radius of Limerick Generating Station that have been determined eligible for Listing in the National ~egister of Historic Places.

Site Name Location PHMC Site #

Hartenstine Heritage Site 2 limerick Twp., Montgomery Co. 36MG0345 Hartenstine Heritage Site 3B limerick Twp., Montgomery Co. 36MG0347 Potts-Saylor Mill Race Pottstown Borough, Montgomery Co. 36MG0277

Ms. Jean Cutler Attachment 2 January 19, 2011 Page 1 of 4 Attachment 2 Previous Cultural Resource Impact Investigations of LGS Features

Ms. Jean Cutler Attachment 2 January 19, 2011 Page 20f4 Attachment 2 - Previous Cultural Resource Impact Investigations of LGS Features LGS Plant Site In 1972, Charles H. Holzinger of Franklin & Marshall College and geologist James A.

Humpreville were contracted by the engineering firm Buchart-Horn, Inc. to conduct an archaeological survey of the LGS plant site (roughly equivalent to today's Phase I investigation),

as well as of the associated Perkiomen Pumphouse, located on Perkiomen Creek. This studi was performed after the start of initial clearing activities for the plant's construction, and sought to identify any prehistoric Native American archaeological sites contained within the property (no attempt was made to document historic period resources). Researchers conducted background research, interviewed local collectors, inventoried privately held artifact collections, and completed a field reconnaissance of the property in conjunction with limited subsurface testing (coring, test units, and mechanical trenching). The completion of this study resulted in the identification of four discreet areas of prehistoric occupation, three of which were located on the western shores of the Schuylkill River, in the vicinity of Frick's Lock in Chester County. The other artifact locus was situated on the eastern side of the Schuylkill, in Montgomery County.

All of these sites had previously been identified by local artifact collectors; aSSOCiated diagnostic tools dated those occupations to the Archaic, Early Woodland, and Middle Woodland culture periods.

In December 1986 John Milner Associates, Inc. completed an architectural and historical analysis of the Frick's Lock District, located in the East Coventry Township section of the Limerick property. This investigation2 incorporated documentary research and on-site investigations to assess the historical and architectural significance of this 18-acre agricultural hamlet and commerce center. This study identified a total of 20 historic buildings and six historic structures that contributed to the overall significance of this district. The buildings examined were all built between 1757 and 1937 and form part of cohesive farming hamlet that documents the local evolution of rural domestic and agricultural architecture in this vicinity.

Other structures identified within the district were directly related to this community's association with the Schuylkill Navigation Company's Girard Canal (ca. 1820-1890). and include the infilled remains of Locks no. 54 and 55 and the former Lock Keeper's House. The report of this investigation determined that the Frick's Lock District demonstrated considerable integrity with respect to the individual buildings present and its general setting as a whole, and concluded that the district did meet the criteria for listing in the National Register of Historic Places. The Frick's Locks Historic District was placed on the NRHP in 2003 under National Register Criteria A and C.

In 2010, Abplanalp completed the Historic and Architectural SUNey of Frick's Lock Historic 3

District for Frens & Frens Architects on behalf of Exelon. The purpose of the study was to evaluate the integrity and historic significance of the architectural resources within the historic I Holzinger, Cha/1es H. and James A. Humpreville. 1972. Archaeological Report, Limerick Generating Station Sile, Montgomery and Chester Counties, PA. Report prepared for Buchart-Horn, Inc. and the Philadelphia Electric Company.

2 O'Bannon, Patrick. 1987. Architectural and Historical Documentation of the Frick's Lock District, East Coventry Township, Chester County, Pennsylvania. Report prepared for the Philadelphia Electric Company. John Milner Associates, Inc.

3 Abplanalp, Kathleen M. 2010. Historical and Architectural SUNey of Frick's Lock Historic District, East Coventry Township, Pennsylvania. Report prepared for Excelon Nuctear.

Ms. Jean Cutler Attachment 2 January 19, 2011 Page 30f4 district and assess the continued viability of the district as a property listed on the NRHP. The study concluded that the current historic district boundaries appear appropriate.

LGS Makeup Water Supply System Archaeological survey was conducted for the vicinity of the Bradshaw Reservoir prior to its construction (ER No. 1981-0382-017).4 Fieldwork consisted of surface survey and the excavation of one test pit. No artifacts were found. A map of the exact survey area was not included in the report. The CRGIS shows a small area of survey extending into the western portion of the Bradshaw Reservoir area.

No previous archaeological surveys are shown in the CRGIS in the area of the Bedminster Water Processing Facility.

The Perkiomen Pumphouse was surveyed as part of the 1972 Buckhart-Horn survey discussed above. The survey found the area to be 'largely disturbed by sewer construction. No archaeological resources were identified.

LGS Transmission System Archaeological surveys were conducted during the mid- to late 1980s for five transmission lines:

Lines 220-60, 220-61, 220-62, 220-63, and 5031. Reports of the surveys were reviewed under ER No. 1981-2021-042. The goals of these investigations were to locate, identify, and evaluate archaeological resources within the transmission line rights-of-way. If a significant archaeological resource was located within a right-ot-way and could not be avoided, a Phase III data recovery program was developed and implemented for the resource. All mitigative measures were reviewed and approved by the PHMC.

Line 220-60 extends along a 7.4-linear-mile corridor on the eastern side of the Schuylkill River from the Limerick 230-kV Substation southeast to the Cromby Substation located at Exelon Generation's Cromby Generating Station in East Pikeland Township, Chester County.s Eleven archaeological sites were investigated. None of the potentially significant sites extended into the areas of proposed transmission line structures. Hence, construction of Line 220-60 was found to have no effect on significant archaeological resources.

Line 220-61 extends for a distance ot 8.53 linear miles on the west bank of the Schuylkill River from the Limerick 230-kV Substation south to the Cromby Substation. s Ten archaeological sites were investigated. Archaeological data recovery was completed to mitigate potential adverse effects at one significant prehistoric archaeological resource, the Frick's Lock Site (36CH103).

4 Neshaminy Water Resources Authority. 1979. Environmental Report on Neshaminy Water Supply System, Bucks County, Pennsylvania.

5 Zatz, K. L., K. M. Joire', and R F. Hoffman. 1984. A Descriptive Report of an Archaeological Investigation for the 220-60 Transmission Line Right-of-Way in Association with the Limerick Nuclear Generating Station, Montgomery and Chester Counties, Pennsylvania. Report submitted to the Philadelphia Electric Company. John M. Milner Associates, West Chester, PA.

6 Zatz, K. L.. K. M. Jofre'. and R. F. Hoffman. 1984. A Descriptive Report of an Archaeological Investigation for the 220-61 Transmission Line Right-of-Way in Association with the Limerick Nuclear Generating Station, Montgomery and Chester Counties, Pennsylvania. Report submitted to the Philadelphia Electric Company. John M. Milner Associates, West Chester, PA.

Ms. Jean Cutler Attachment 2 January 19, 2011 Page 4 of4 The remaining nine archaeological sites were determined to not extend into areas of proposed transmission line structures. Hence, construction of Line 220-61 was found to have no adverse effect on significant archaeological resources.

Une 220-62 extends for a distance of 16 linear miles from the Cromby Substation eastward to the North Wales Substation in Upper Gwynedd Township, Montgomery County.7 Seventeen previously unrecorded sites were found, along with one isolated find. Investigations revealed that no potentially significant sites were present within the areas of proposed transmission line structures. Therefore, construction of Une 220-62 was found to have no adverse effect on significant archaeological resources.

Line 220-63 extends for a distance of 14 linear miles from the Cromby Substation east to the Plymouth Meeting Substation in Plymouth Township, Montgomery County.s Presently, this line is segmented, with the first segment (Line 220-63) extending from the Cromby Substation to the Barbadoes Substation and the second segment (Une 220-64) extending from the Barbadoes Substation to the Plymouth Meeting Substation. Fourteen archaeological sites and two lithic scatters were identified. Site 36MG156 was considered eligible for the National Register. The significant data was recovered during the Phase I and II investigations and no further work was conducted. Data recovery was completed at the Indian Point Site (36CH53), a significant prehistoric site dating to the Early-Middle Woodland period. The remaining 12 sites were found not to extend into areas of proposed transmission line structures. Therefore, construction of Line 220-63 was found to have no adverse effect on significant archaeological resources.

Archaeological survey for Line 5031 covered 16 linear miles, extending from the Limerick 500 kV Substation to the Whitpain Substation in Whitpain Township, Montgomery County. 9 Approximately three miles of the ROW is shared with Line 220-62 and was surveyed as part of that archaeological project. Two archaeological sites were investigated, neither of which was considered eligible for the National Register. Hence, construction of Line 5031 was found to have no adverse effect on significant archaeological resources.

7 Zatz, Karyn L, K. M. Joire', R. F. Hoffman, and M. Parrington. 1984. A Descnptive Report of an Archaeological Investigation for the 220-62 Transmission Line Right-of-Way in Association with the Limerick Nuclear Generating Station, Montgomery and Chester Counties, Pennsylvania. Report submitted to the Philadelphia Electric Company. John M. Milner Associates, West Chester, PA.

S Zatz, KL, K.M. Joire', R.F. Hoffman, and M.J. Rast. 1985. A Descriptive Report of an Archaeological Investigation for the 220-63 Transmission Line Right-of-Way in Association with the Limerick Nuclear Generating Station, Montgomery and Chester Counties, Pennsylvania. Report submitted to the Philadelphia Electric Company. John M. Milner Associates, West Chester, PA.

9 Zatz. KL., J.A. Robertson, and T.L. Struthers. 1989. A Descriptive Report of an Archaeological Investigation for the 5031 Transmission Line Right-of-Way in Association with the Limerick Nuclear Generating Station, Montgomery County, Pennsylvania.

Report submitted to the Philadelphia Electric Company. John M. Milner Associates, West Chester, PA.

Ms. Jean Cutler Attachment 3 January 19, 2011 Page 1 of 10 ATIACHMENT3 Figures Depicting LGS Project Features Figure 1 LGS Plant Site Property Boundaries Figure 2 Perkiomen Pumphouse Figure 3 LGS Makeup Water Supply System Figure 4 Bradshaw Reservoir and Bradshaw Pumphouse Properties Figure 5 Bedminster Water Processing Facility Property Figure 6 Limerick to Cromby 230 kV Transmission Line Route Figure 7 Cromby to North Wales 230 kV Transmission Line Figure 8 Cromby to Plymouth Meeting 230 kV Transmission Line Route Figure 9 Limerick to Whitpain 500 kV Transmission Line Route

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COmmonwealth of Pennsylvania Pennsylvania Historical and Museum Commission Bureau for Historic Preservation Commonwealth Keystone Building, 2nd Floor . i 1 400 North Street (\ \ I' f l

\d I f Harrisburg, PA 17120-0093 I \/

wVv"w.plunc.state.pa.us

. February 16,2011

.'1':'-) \I Michael P. Gallagher Exelon Nuclear 200 Exelon Way, KSAJ2-E Kennett Square, P A 19348 Re: File No. ER 2004-2024-091-B NRC: Renewal ofOperating Licenses for Limerick Generating Station, Units 1 & 2, Limerick, Londonderry & Peach Bottom Twps.

Montgomery Co.

Dear Mr. Gallagher:

The Bureau for Historic Preservation (the State Historic Preservation Office) has reviewed the above named project in accordance with Section 106 of the National Historic Preservation Act of 1966, as amended in 1980 and 1992, and the regulations (36 CFR Part 800) of the Advisory Council on Historic Preservation.

These requirements include consideration of the project's potential effect upon both historic and archaeological resources.

There may be historic buildings/structuresldistrictslobjects eligible for the National Register of Historic Places located in the project area. However, due to the nature of the activity, it is our opinion that there will be no effect on these properties. Should the scope and/or nature of the project activities change, the Bureau for Historic Preservation should be contacted immediately.

In our opinion no archaeological investigations ate necessary in this project area.

If you need further information in this matter please consult Susan Zacher at (717) 783-9920.

Sincerely,

~'~7~

Douglas C. McLearen, Chief Division of Archaeology &

Protection DCMltmw

T. McCulloch -3 The Limerick license renewal application is available on the internet at http://www.nrc.gov/reactors/operating/licensing/renewal/applications/limerick.html.

If you have any questions or require additional information, please contact Ms. Lisa M. Regner, License Renewal Project Manager, by phone at 301-415-1906 or bye-mail at Lisa. Reg ner@nrc.gov.

Sincerely, IRA! by Lisa M. Regner for David J. Wrona, Chief Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosures:

As stated cc: Listserv DISTRIBUTION:

See next page ADAMS Accession Nos.:

Package: ML11245A085 Letter: ML11245A083 Enclosures 1&2: ML11245A089

  • Concurrence via e-mail OFFICE LA: DLR/RPB2* PM: DLR/RPB2 LA: DLR/RPB2* BC:DLR/RPB2 NAME IKing LRegner IKing DWrona (LRegner for)

DATE 09/14/2011 09/16/2011 09/14/2011 09/16/2011 OFFICIAL RECORD COpy

Letter to Tom McCulloch from David J. Wrona dated September 16,2011

SUBJECT:

LIMERICK GENERATING STATION LICENSE RENEWAL ENVIRONMENTAL REVIEW (SHPO FILE NO. ER 2004-2024-091-B)

DISTRIBUTION:

HARD COPY:

L. Regner E-MAIL:

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